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Whistleblowing Policy for

Staff in Schools

Schools’ HR Service

March 2013

Updated June 2020

Reviewed by Governors June 2020

Next Review Date June 2022

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CONTENTS

Section 1

Introduction page 4

Section 2 Raising concerns page 9

Section 3 Dealing with your concern page 12

Section 4 The investigation procedure page 14

Section 5 If you are dissatisfied page 17

Appendix 1 Examples of concerns that may be raised page 18

Appendix 2 Flow chart – reporting concerns through the

Whistleblowing Policy

page 20

Appendix 3 Flow chart – managing a concern through the

Whistleblowing Policy

page 21

Appendix 4 Useful contacts page 22

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PREAMBLE

This policy provides guidance for staff about how to raise concerns using the

Whistleblowing Policy. It states their duty to report concerns whilst providing a

framework in which those concerns can be raised. It also provides guidance for

Headteachers, Chairs of Governors and line managers on how to manage the

investigation of such concerns and the individuals who raise them.

[If you wish to report a concern about the local authority rather than the school, or you

are employed by the local authority and are managing a concern made against it,

please also refer to the Sheffield City Council Whistleblowing Policy, which is based

upon the same principles as this document. This is available from Sheffield City Council

Human Resources (0114 2734299). Whilst the investigation will take place under the

terms of that document, employees of # School will still be protected under the terms of

this policy.]

The Whistleblowing Policy has been designed for Local Authority maintained schools.

Where an establishment which is not maintained but intends to adopt the content or

principles of this policy, it is recommended that the establishment takes independent

legal advice in order to gain clarity on any implications of the legislation and principles

in this document. Any such establishment should also remove the sections highlighted

in red, which relate specifically to Local Authority maintained schools.

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SECTION 1 INTRODUCTION

The Governing Body of Broomhill Infant School adopted this policy for employees of the

school on 25th January 2017

The Governing Body will review it every 2 years

1.1 Introduction

Most of us, during our working life, have concerns about what is happening in the

workplace. Usually, these issues are easily resolved – but when they are about

unlawful conduct, financial malpractice or dangers posed to people or the environment

it can be difficult to know what to do next.

You may be worried about raising such concerns or you may want to keep them to

yourself. Perhaps you feel the issue at hand is none of your business or that it’s only a

suspicion for which you have little evidence. You may feel that raising the matter would

be disloyal to colleagues, governors, the Headteacher or the school. You may decide to

say something but find that you have spoken to the wrong person or raised the issue in

the wrong way and are not sure what to do next.

1.2 Purpose

This policy is designed to enable you to raise your concerns at an early stage and in the

right way. As an employee of the school, it is your duty to raise these concerns. The

governors and the Local Authority (LA) believe that helping you to do so is an important

part of ensuring that the school is well-run and safe.

Providing the concern is genuine, the school would prefer you to raise it as soon as

possible rather than waiting for proof; if it falls within the areas listed below, we ask that

you do so using this procedure.

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1.3 Application of the Policy

The Whistleblowing Policy is intended to cover genuine concerns that are not covered

by other procedures and which you think the school and the Local Authority should look

into.

Such concerns include:

Unlawful conduct

Financial malpractice

Causing a danger to children and young people

Causing a danger to staff, the public or the environment

Contravening the governing body’s policies or the school’s code of

conduct

Deliberate concealment of any of the above

In Appendix One, we have provided some examples of the kind of issues the governing

body would consider as malpractice or wrong-doing that could be raised under this

policy. This should not, however, be regarded as a complete list – If you are in doubt

about any issue, raise it.

1.4 Which concerns do not fall within remit of the policy?

The Whistleblowing Policy is primarily for concerns where the interests of other people

or the organisation are at risk. It only applies if you are raising a concern in the public

rather than your own individual interest.

If your concern is about your personal position in school or the way you as an individual

have been treated, please raise it through the Grievance Procedure. A copy of this

procedure is available in school.

Where a concern is raised about an individual or individuals, once the concern has

been investigated under the Whistleblowing Policy, there may be a need for further

investigation or action. This would take place within the framework of a different policy.

Where this is the case, you will be notified that the investigation under the

Whistleblowing Policy has ended.

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1.5 Your obligation to report concerns

As an employee of the school, the school’s code of conduct requires you to report

genuine concerns of fraud, theft or unethical behaviour etc. This policy provides you

with ways of doing that.

If you are concerned that a young person is at risk of harm, the guidance in the DfE’s

Keeping Children Safe in Education 2016 document and the Management of

Allegations of Abuse (Schools) Policy obliges you to report your concerns. If you are

concerned that a young person is being harmed or at risk of being harmed, or you have

a concern about a staff member, volunteer or contractor’s suitability to work with

children, you should report this using the Management of Allegations of Abuse Policy.

If, however, you are concerned that:

an individual’s professional practice, or

the leadership and/or management of the school, or

the school’s policies, procedures and/or ways of working

may be undermining the safety and wellbeing of young people, or leaving them

vulnerable to risk, or you are worried about the way in which safeguarding allegations

have been managed, you should express these concerns through the Whistleblowing

Policy.

1.6 Our assurances to you

Your safety

The governing body recognises that the decision to report a concern can be a difficult

one to make and the school and the LA are fully committed to the assurances given in

this policy. If you raise a genuine concern under the Whistleblowing Policy, you will not

be at risk of losing your job or suffering any form of reprisal as a result. The governing

body will not tolerate harassment, bullying or victimisation and will take action to protect

you.

This protection applies not only while you are employed, but also after the working

relationship has ended.

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Provided you are acting in good faith, it does not matter if you are mistaken. However, if

you maliciously raise a matter you know is untrue, disciplinary action may be taken

against you in accordance with the school’s Disciplinary Procedure.

Confidentiality

While we will consider anonymous reports, this makes it much more difficult for us to

look into the matter or give you feedback. However, the governing body recognises that

you may wish to raise a concern in confidence under this policy. If you ask us to protect

your identity by keeping it confidential, we will not disclose it as part of the

Whistleblowing Investigation without your consent.

Please note, however, that the school will not tolerate the harassment, bullying or

victimisation of anyone raising a genuine concern.

Please also note that any confidentiality clause within any other policy, agreement or

contract should not prevent you from raising a genuine public interest concern under

the Whistleblowing Policy.

Your right to support in meetings

In any meetings that have a connection to your whistleblowing concern, you have the

right to be accompanied by your trade union representative or a work colleague

(providing they are not involved in the issue and would not be called as a witness).

These meetings might include:

A meeting with your line-manager or other appropriate person to raise your

concern.

A meeting with an investigation officer in connection with the concern.

Taking part as a witness in any action taken as a result of raising the

concern.

Contact details of trade union representatives can be found in Appendix Four.

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1.7 Independent advice

If you are unsure whether to use this policy, or if you want independent advice at any

stage, you should contact:

Your trade union (contact details for which are provided in Appendix Four)

The independent charity Public Concern at Work whose lawyers are available

give you free confidential advice at any point in the process. Their helpline is

02031172520

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SECTION 2 – RAISING CONCERNS

2.1 How to report a concern

There are a number of different ways to raise a whistleblowing concern – you can

choose the one that suits you. It doesn’t matter which you choose, you can be assured

that a named manager will properly consider it.

Whichever way you decide to raise your concern, please ensure that you state that you

are doing so under the Whistleblowing Policy. (If at any stage we feel that your concern

is a grievance rather than a whistleblowing matter, we will tell you.)

Although you can raise your concern verbally, you may find it easier to do so in writing

– this way, you can keep a record of what you reported as well as giving yourself the

time to make sure you’ve included all the relevant information.

When reporting your concern, you should provide information about the background

and history of your concern. Where possible, you should give names, dates and places

and the reason why you are particularly concerned about the situation. If you are a

member of a trade union, you may find it helpful to take advice from them about putting

your concerns in writing.

There is no reason why you cannot use email to raise a whistleblowing concern.

However, if you do choose to use email, please take extra care to make sure that your

message is sent to the correct person and consider that due to the nature of email

communication it may be read by other people. To help make sure your concerns are

seen and handled quickly, mark the subject box: ‘Whistleblowing – confidential –

recipient only’.

If, however, you do not wish to put your concern in writing, you can telephone or

arrange to meet with the appropriate person.

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2.2 Who to contact with your concern

Your supervisor, line manager or Headteacher

If you have a concern which you believe is covered by the Whistleblowing Policy, we

hope you feel able to raise it first with your immediate line manager.

This may depend, however, on the seriousness and sensitivity of the issues involved

and who you think may be involved in the malpractice.

For example, if you believe that your line manager is involved, you should approach the

Headteacher. If you believe the Headteacher is involved, your Chair of Governors

should be approached and/or one of the LA officers named in Appendix Four.

A Local Authority named officer

If the concern is about the governing body or the LA, you can contact one of the named

LA officers in Appendix Four. If it is about an employee of the LA, your concern will be

investigated under the Sheffield City Council policy rather than the Broomhill Infant

School policy. This is because the school policy only applies to employees of Broomhill

Infant School; in the above circumstance, both the subject of the concern and the

investigating officer are employed by the Council and are therefore covered by the

Council’s policy. The protections set out in this policy will still apply, however, to school

employees raising the concern.

The Council Monitoring Officer

If you feel the matter is so serious that you cannot discuss it with the Headteacher,

Chair of Governors or one of the named LA officers listed in Appendix Four, you can

raise your concern directly with the Council’s Monitoring Officer. (The Monitoring Officer

is responsible for ensuring that the Council, its members and its officers carry out their

functions in a lawful and ethical manner.)

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External contacts

The school hopes this policy gives you the reassurance you need to raise such matters

internally. If, however, you feel unable to raise your concern internally we would much

rather you raise the matter with the appropriate agency than not at all. Provided you are

acting in good faith and you have evidence to back up your concern, you can contact

any of the following:

Your local Council member

External audit

https://www.gov.uk/government/organisations/audit-commission

Relevant regulatory organisations (such as the Department of

Education)

Your solicitor

The police

Other bodies prescribed under the Public Interest Disclosure

Act. These include, but are not limited to the Information

Commissioner’s Office, the Serious Fraud Office, the

Environment Agency, the Health and Safety Executive.

If you do refer your concern to an individual or organisation outside the school or the

LA, you need to ensure that you do not disclose confidential information. You should,

therefore, first check with Legal Services, who will give you confidential advice – you do

not have to give your name if you do not wish to. You will find a contact telephone

number in Appendix Four.

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SECTION 3 – DEALING WITH YOUR CONCERN

3.1 How the school will handle the matter

Once you have told us of your concern, we will look into it to assess what action should

be taken.

In order to protect individuals, the governing body and the LA, initial enquiries will be

made to decide whether an investigation is appropriate and, if so, what form it should

take. Concerns or allegations that fall within the scope of specific procedures (for

example, child protection or discrimination issues) will normally be referred for

consideration under those procedures. If your concern falls more properly within a

different procedure, we will tell you.

Some concerns may be resolved without the need for an investigation.

The length of time it takes for us to respond will depend on the nature of the issue you

are disclosing. If there is a safeguarding or health and safety risk, for example, we will

contact you immediately. Whatever the nature of your disclosure, the governing body

will write to you within at least ten working days to:

Acknowledge that the concern has been received

Indicate how we propose to deal with the matter

Give an estimate of how long it will take to deal with the matter

Tell you whether any initial enquiries have been made; and

Tell you whether further investigations will take place, and if not, why not.

If a further investigation is required, this may involve:

An internal investigation

Referral to the police

Referral to an external auditor

An independent enquiry

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The school or LA officer will tell you who is handling the matter, how you can contact

them and whether further assistance may be needed from you.

3.2 Your right to the support of a trade union representative or colleague

When any meeting is arranged to discuss your concerns, you have the right to be

accompanied by a trade union representative or a colleague (who is not involved in the

area of work to which the concern relates and who also who could not be called as

witness).

3.3 Our commitment to support you through the process

The governing body or LA will take steps to minimise any difficulties, which you may

experience as a result of raising a concern. For instance, if you are required to give

evidence in criminal or disciplinary proceedings, the governing body or LA will advise

you about the procedure.

If you are asked to attend a meeting, we will aim to give you a minimum of ten days

notice.

The governing body and the LA accept that you need to be assured that the matter has

been properly addressed. Thus, subject to legal constraints and confidentiality, you will

receive information about the outcome of any investigations.

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SECTION 4 – THE INVESTIGATION PROCEDURE

4.1 Verification

Concerns raised under this procedure may be resolved by the person to whom they

were reported. This could be your supervisor, line-manager or the Headteacher.

If they are not able to resolve the matter or you have raised your concern with the Chair

of Governors and named LA officer, they will make initial enquiries to assess whether

an investigation is required and, if so, what form that investigation should take.

If you did not raise your concerns directly with the Chair of Governors, unless the

disclosure refers to them they will still be notified for monitoring purposes (see

paragraph 4.4).

Although you are not expected to prove the truth of any allegation, you will need to

demonstrate that there is a sufficient reason for expressing your concern. This policy

provides protection to employees who raise issues in the genuine belief that there is

serious cause for concern. If the complaint is found to be in bad faith, disciplinary action

may be considered.

If it is confirmed that the Whistleblowing Procedure is the appropriate route and that an

investigation is required:

The concern will be recorded

An Investigating Officer will be identified

You will be told who will investigate and the likely timescale for the investigation

within ten days

If there is insufficient information to make a decision about the most appropriate course

of action, you will be asked for more information.

If it is decided not to investigate further, you will be told what enquiries have been made

and the reasons for the decision.

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When any meeting is arranged to discuss your concerns, you have the right to be

accompanied as outlined in paragraph 3.2.

4.2 The investigation

The Investigating Officer may ask you to put your concerns in writing and provide as

much evidence as possible. It may also be necessary to ask you to provide a witness

statement. You will have the opportunity to confirm that the information you have

provided is accurate and complete before it is used in the investigation.

You will be asked to agree that the information you have provided and your name may

be disclosed so that the Investigating Officer can decide how the governing body or LA

will respond and investigate the issue.

If you do not want to disclose your identity the Investigating Officer will decide how to

proceed.

The Investigating Officer may need to contact you or other witnesses during the

investigation.

The investigation will be carried out as quickly as possible but the time taken will

depend on the nature of the issues raised and the availability and clarity of the required

information. You will be updated at 28 day intervals unless this is not practicable.

If you are required to take part in the investigation you have the right to be

accompanied as set out in paragraph 3.2.

4.3 The outcome

The investigation will be concluded with a written report of enquiries made, the findings

on the strength of the evidence and whether the substance of the allegations has been

established.

Where legal and confidentiality constraints allow, you will receive information about the

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outcome of any investigation. If the investigation continues within the framework of

another procedure, the school will, if able, inform you of this.

If, however, the provision of further information would result in the school breaching an

individual’s confidentiality or the law, we may not be able to you, as the person who

made the disclosure, whether the investigation has continued under the framework of

other policies since to do so may jeopardise the outcome of any further investigation.

We will, however, inform you that the investigation is concluded under the framework of

the Whistleblowing Policy.

If the investigation concludes that the allegations are not substantiated, the report will

conclude whether the concerns were raised in good faith.

4.4 Monitoring

Within the school, a central record of all whistleblowing complaints, including dates,

substantive issues, findings and outcomes is retained by the Chair of Governors. The

Chair will report as necessary to the governing body in a way that maintains your

confidentiality as far as possible.

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SECTION 5 – IF YOU ARE DISSATISFIED

If you are unhappy with our response, remember you can use the other routes detailed

in this policy in paragraphs 1.7 and 2.2.

While we cannot guarantee that we will respond to all matters in the way that you might

wish, we will try to handle the matter fairly and properly. By using this policy, you will

help us to achieve this.

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APPENDIX ONE – EXAMPLES OF CONCERNS THAT MAY BE RAISED

This list shows the kind of issues that may be raised under the Whistleblowing Policy.

However, there may be other concerns that can be raised under the policy that are not

shown here; if you are aware of such an issue, please report it.

Poor or unprofessional practice by a member of staff or an agency that results in the

service user not getting the same quality of service which is available to others.

Children or young people being put at risk by an individual’s professional practice, or

the leadership and/or management of the school, or the school’s policies, procedures

and/or ways of working.

Allegations of a safeguarding nature not being taken seriously or appropriately

handled.

Improper/unacceptable behaviour towards employees, volunteers, contracted

workers or service users which could take the form of emotional, sexual or verbal

abuse, rough handling, oppressive or discriminatory behaviour or exploitative acts for

material or sexual gain.

Any unlawful activities, whether criminal or a breach of civil law.

Fraud, theft or corruption.

Concerns regarding possible breaches of Health and Safety regulations.

Harassment, discrimination, victimisation or bullying of employees, volunteers,

contracted workers and/or service users.

Leaking confidential information in respect of governing body activities or records.

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Misuse of pupil, employee, volunteer or financial data (including attainment

information and personal details).

Doing undisclosed private work which may conflict with working for the school or

which is being carried out during working time.

Inappropriate contact with members of the public within school facilities, or whilst

carrying out school duties outside of working time.

Taking gifts or inducements.

Inappropriate use of external funding or the school budget.

Maladministration as defined by the Department of Education, Local Government

Ombudsman or appropriate examination boards.

Breach of any statutory code of practice.

Breach of, or failure, to implement, or comply with any governing body policy.

Misuse of school asset], including, but not limited to, computer hardware and

software, buildings, stores, vehicles and/or equipment.

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APPENDIX TWO – REPORTING CONCERNS THROUGH THE WHISTLEBLOWING POLICY ____________________________________________________________________________________________________________

Does your concern involve the actions of the Headteacher?

Does your concern relate to the actions of a governor or

governors?

Does your concern relate to the actions of a person or people

employed by the school?

Does your concern relate to the actions of someone employed

by the City Council?

Report your concern to a Local Authority named officer or, if an academy, to the

Trust or Secretary of State (see section 2.2)

Does your concern relate to the actions of volunteers or staff

contracted to work in the school (e.g. supply staff)

Report your concern to the Headteacher

(see section 2.2)

Would you be comfortable disclosing your concern to the

Chair of Governors?

Report your concern to the Chair of Governors

(see section 2.2)

YES NO

YES

NO

NO

NO

NO

YES

YES

YES

YES NO

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APPENDIX THREE – MANAGING A CONCERN THROUGH THE WHISTLEBLOWING _____________________________________________________________________

Concern reported

Does concern fall within the scope of the school’s Whistleblowing Policy? (See sections 1.3-4 & Appendix 1)

Concern examined under another policy.

Whistleblower informed.

The Whistleblower’s concern is acknowledged in writing (see section 3.1)

Initial enquiries are made. Is an investigation

required?

Whistleblower and Chair of Governors/Monitoring Officer

informed of outcome

The form of the investigation and the

identity of the investigating officer will be decided (see

section 4.1)

Whistleblower and Chair of Governors/Monitoring

Officer informed

Investigation takes place. Whistleblower updated

every 28 days if possible. (See section 4.2)

Has the investigation resulted in individuals being subject to further investigation under another policy?

Written report of findings and further actions. Whistleblower informed of outcomes as far as confidentiality

allows. (See section 4.3)

Written report of findings and further actions. Whistleblower informed of outcomes as far as

confidentiality allows. Investigation continues under relevant policy. Whistleblower’s involvement ends.

(See section 4.3)

Findings shared with Chair of Governors/Monitoring Officer. Details

retained in central record. Governing Body notified if appropriate. (See section 4.4.)

YES

NO

NO

YES

YES NO

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APPENDIX FOUR – USEFUL

Please note that the contact details below were correct as of September 2012.

For employee issues

EPM HR Advisors

01480 423449

For educational issues

Deputy Executive Director, CYPF Portfolio

0114 2930968

For governance issues

Principal Officer – Governors

0114 2506889

For financial issues

Director of Finance, Resources

0114 2735872

EPM

01480 277 455

For child safety issues

Local Area Designated Officer

0114 2734934

Legal Services

Legal Service Manager

0114 2736564

Council Monitoring Officer

0114 2734018

Trade Union representatives

ASCL 0116 2991122 NUT 0870 2407714

GMB 0845 3377777 Unison 0114 2736307

NASUWT 0114 2757015 NAHT 0300 3030333

ATL 07748 351775 Unite 0114 3210702

All telephone numbers correct at time of reviewing